For assessment year 96-97, the learned assessing officer, on examination of the profit and loss account of the assessee and the details obtained during the course of hearing under section 143 (3)of that year found that assessee company has provided interest of Rs. 71,03,37,564/- on deposits collected under GFDA scheme floated by assessee and debited the same to the profit and loss account by applying the average rate of interest on the balance amount of deposits bypassing monthly credit entries in the interest payable account without crediting the corresponding interest accrued on each individual deposit to the individual depositors account. As assessee did not deduct any tax from the above interest provision credited to the interest payable account, ld AO was of the view that provisions of section 194A of the act are applicable. Therefore, assessee was issued a show cause notice with respect to the applicability of provisions of section 201 (1) of the act and why interest under section 201 (1A) may not be charged.